"It is imperative that security officials hear directly from members of the general aviation community and air traffic controllers about the practical difficulties and economic hardships caused by this highly restrictive airspace," AOPA President Phil Boyer told Deputy Secretary of Homeland Security Michael P. Jackson. "Simply reviewing and responding to written comments does not afford the proper opportunity for questions, discussion, and the exploration of alternatives."

AOPA contacted Jackson instead of the Transportation Security Administration because of the "numerous DHS agencies involved in Washington-area airspace security."

Boyer reminded Jackson of the huge dimensions of the ADIZ - 90 miles at its widest point, and stretching from "the tip of West Virginia, across the Chesapeake Bay to Maryland's Eastern Shore, north beyond Baltimore and south to just outside of Fredericksburg, Virginia." Inside the ADIZ are 19 public-use airports, more than 10,000 pilots, and 2,655 aircraft. More than 1 million flights a year move through that airspace.

"The air traffic control system is being required to perform a function for which it was not designed and for which it lacks capacity," Boyer said, noting that, at times, controllers' workload has almost quadrupled since the imposition of the ADIZ.

"In addition, small businesses dependent upon providing services to light aircraft pilots in the Washington, D.C., area are losing nearly $30 million a year.

"Jobs have been lost, flight schools have closed, and many pilots have either stopped flying or moved their aircraft out of the area," Boyer told the DHS.

He also said that GAO and Congressional Research Service reports had raised questions about the continuing need for this "hastily crafted solution implemented during a heightened security threat period."

Boyer also noted that more than 14,000 comments (as of October 28) had been filed against the ADIZ, the largest number of comments from individual pilots on a proposed FAA rulemaking in more than a quarter of a century.